What should a GPSR technical documentation file contain for a simple consumer product?

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Jason van de Zande

A GPSR technical documentation file is the set of documents that shows a consumer product is safe and that you have assessed and controlled its risks under the General Product Safety Regulation (EU) 2023/988 (GPSR). For a simple product, it usually includes clear product identification, a risk assessment, evidence such as test results where appropriate, and the final labels and instructions. Below are the key questions authorities and marketplaces typically expect you to answer.

What is a GPSR technical documentation file, and when is it required?

A GPSR technical documentation file is the manufacturer’s documented proof that a product placed on the EU market meets the GPSR general safety requirement. It must be drawn up before the product is placed on the market, kept up to date, and retained for ten years after the product is placed on the market.

The manufacturer must have this documentation available for market surveillance authorities on request. Where the manufacturer is not established in the EU, the designated GPSR Responsible Person, as an economic operator, must also be able to provide the documentation to the authorities on request. If your product is also covered by EU harmonisation legislation (for example, CE marking rules), you will typically maintain that technical documentation as well and use the GPSR file to cover any safety risks not addressed there.

What should a GPSR technical documentation file contain for a simple consumer product?

For a simple consumer product, a GPSR technical file should contain enough information to identify the product, explain how it is made and used, and show how you assessed and reduced risks. The goal is for an authority to be able to review the file and understand why the product is considered safe under normal and reasonably foreseeable conditions.

  • Product identification and traceability: model or type, SKU, batch or serial format (if used), product photos, and a clear link between the product, packaging, and listing identifiers.
  • Description of design and manufacturing: materials, key dimensions, critical components, and a high-level manufacturing process description (including outsourced steps).
  • Intended use and reasonably foreseeable misuse: who it is for, where it is used, and predictable misuse scenarios (for example, use by children when not intended, or use near heat sources).
  • Risk assessment and risk reduction measures: identified hazards, risk evaluation, and the controls you applied (design changes, guards, warnings, packaging, quality checks).
  • Applicable requirements and standards used: EU and national safety expectations considered, and any standards applied (note if applied only in part).
  • Test reports and other evidence: relevant test results, material declarations, supplier test data, and checks that support your risk controls (only what is appropriate for the product and risks).
  • Instructions and safety information: user instructions, warnings, disposal information where relevant, and language versions for the Member States where you sell.
  • Labelling and packaging artwork: final label files, packaging layouts, and photos showing the markings are legible and durable, including manufacturer contact details and Responsible Person details where required.
  • Supply-chain details for traceability: manufacturer site details, key suppliers, and records that let you trace affected units if a safety issue arises.

How do you compile and maintain a GPSR technical file that is ready for inspections?

You compile an inspection-ready GPSR technical file by building a controlled document set that is complete, consistent, and quickly retrievable. Start with a simple index, then add only documents that support product identification, safety assessment, and risk controls, and keep them aligned with the product you actually ship.

  1. Gather inputs from design, quality, production, and suppliers, including the latest label, manual, and any test evidence.
  2. Create a document index with file names, versions, dates, and which product model or variant each document covers.
  3. Apply version control so you can show what changed, when, and why, especially for safety-related updates.
  4. Record corrective actions taken after complaints, accidents, or internal findings, and link them to updated risk assessments and labels.
  5. Store it accessibly in the EU (electronic is acceptable), so it can be provided promptly to authorities on request.
  6. Set review triggers: a design or supplier change, a new complaint trend, an accident report, a new or revised standard, or a change in where you sell.
  7. Prepare a rapid-response package: index, risk assessment summary, labels, instructions, and key evidence, ready to share when requested.

How does EARP help with GPSR technical documentation for simple consumer products?

We help non-EU manufacturers and sellers keep GPSR technical documentation organised, complete, and ready to provide to EU authorities through our EU Responsible Person services. Our support is practical and documentation-focused, so you can keep selling while meeting GPSR and Market Surveillance Regulation (EU) 2019/1020 (MSR) expectations.

  • We perform completeness checks against typical GPSR technical documentation expectations for simple consumer products.
  • We provide secure documentation storage and structured indexing for fast retrieval.
  • We make documentation available to authorities on request in line with the Responsible Person role.
  • We flag documentation gaps and consistency issues that commonly cause marketplace or authority questions.

To discuss your product and what you already have, contact us via our contact page, or review our services to see how we can support your GPSR compliance workflow.

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